0000894579-01-500119 Sample Contracts

Accepted By: /s/ Mary F. McCollum ------------------------ Mary F. McCollum Secretary and Treasurer
Expense Limitation Agreement • October 31st, 2001 • Bramwell Funds Inc

This letter will confirm our binding commitment to you that Bramwell Capital Management, Inc., the investment adviser to the Bramwell Growth Fund (the "Fund"), has agreed to subsidize the Fund such that the total expenses of the Fund (excluding interest, taxes, brokerage and extraordinary expenses) do not exceed an annual rate of 1.75% of the Fund's average net assets for the fiscal years 2002 and 2003.

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FORM OF SERVICING AND DISTRIBUTION AGREEMENT
Servicing and Distribution Agreement • October 31st, 2001 • Bramwell Funds Inc • New York
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